SETTLEMENT AGREEMENTSettlement Agreement • November 16th, 2020
Contract Type FiledNovember 16th, 2020This Settlement Agreement (this “Settlement Agreement”) is made by and among: (i) individual and representative plaintiff David Zouzout (“Plaintiff”), on behalf of himself and, on the terms set forth herein, the Settlement Class (as defined below) on the one hand; and (ii) Canada Dry Motts Inc., a corporation existing under the laws of Canada (“CDM”) and Keurig Dr Pepper Inc., a corporation existing under the laws of the United States of America (“KDP” together with CDM, collectively, “Defendants”, and Plaintiff and Defendants being collectively referred to herein as the “Parties”) on the other hand, by and through their respective counsel and representatives, as of the 12th day of November 2020, to settle and compromise the claims of Plaintiff and the Settlement Class on the terms and conditions set forth below: